“We feel this project presents an unacceptable risk to wildlife. We are particularly concerned with potential significant adverse impacts upon bats and birds. … This project, and the conditions imposed by the State Corporation Commission, will set a precedent for all future wind energy projects in Virginia. Wind farms cannot be viewed as independent with regard to impacts upon wide-ranging migratory animals. We currently lack sufficient knowledge to absolutely determine the maximum fatality rates that can be tolerated at a given site without unacceptably impacting local or regional populations of sensitive species; but we are certain that high fatality rates at multiple sites across the landscape would pose an unacceptable risk, as do unmitigated fatalities of Endangered or Threatened species. … In the case of this project, where wildlife losses potentially could be very substantial and significant, we must take a conservative approach to assessing risk and designing appropriate mitigation. The data needs for pre- and post-construction evaluation, monitoring, and mitigation should not be dictated by project applicants or consultants …. High fatality rates at this site would particularly be devastating to bats because of their reproductive strategy, which is atypical of a small mammal. … They have small litters (typically one or two young), only one litter per year, and life expectancy of 12-15 years. With this strategy, the impact of the loss of individuals is much greater, especially within small populations. … In addition to bats, we are concerned over potential eagle fatalities at this site. … We have recommended that the applicant consult with the U.S. Fish and Wildlife Service concerning potential take of federal Endangered or Threatened species. We cannot authorize take of federally listed species. The applicant’s consultants have downplayed the potential for such take but, in our opinion, the evidence suggests a strong likelihood of take.”
Download original document: “Reply to Highland New Wind Development, LLC”
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